05000324/LER-2017-001

LER-2017-001, Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 3

Brunswick Steam Electric Plant (Bsep), Unit 2
Event date:	03-22-2017
Report date:	05-18-2017
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3242017001R00 - NRC Website

LER 17-001-00 for Brunswick, Unit 2, Regarding Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 3

ML17142A163
Person / Time
Site:	Brunswick
Issue date:	05/18/2017
From:	Gideon W R Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 17-0045 LER 17-001-00
Download: ML17142A163 (5)

Background

Initial Conditions At the time of the event, Unit 2 was in Mode 5 (i.e., Refuel), at zero percent of rated thermal power (RTP).

Reportability Criteria On January 15, 2016, the NRC issued EGM 11-003, Revision 3, which provides generic enforcement discretion to allow implementation of specific interim actions as alternative to full compliance with plant TSs related to secondary containment operability during Mode 5 OPDRV activities. To ensure compliance with EGM 11-003 OPDRV Activities." This procedure, which implements compensatory actions that meet or exceed those specified in EGM 11-003, Revision 3, was implemented on one occasion during the 2017, Unit 2 refueling outage. The following list provides the duration of the period during which EGM 11-003, Revision 3, was implemented (i.e., OPDRV activities were in progress with secondary containment inoperable). Unit 2 was in Mode 5 during this period.

On March 22, 2017, Unit 2 implemented the guidance of EGM 11-003, Revision 3, “Enforcement Guidance Memorandum 11-003, Revision 3, Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specification Containment Requirements during Operations with a Potential for Draining the Reactor Vessel,” dated January 15, 2016. Consistent with EGM 11-003, Revision 3, secondary containment [NG] operability was not maintained during Operations with a Potential for Draining the Reactor Vessel (OPDRV) activities, and Required Actions C.1 and C.2 of Technical Specification (TS) 3.6.4.1, “Secondary Containment,” were not completed. This condition is being reported in accordance with 10 CFR 50.73(a)(2)(i)(B) as operations prohibited by the plant's TSs.

6 days, 0 hour0 days <br />0 hours <br />0 weeks <br />0 months <br />, 21 minutes Implementation of EGM 11-003, Revision 3, during the Unit 2 refueling outage was a planned activity. As such, there was no causal evaluation of the event.

Event Description

Event Causes

CONTINUATION SHEET

(See NUREG-1022, R.3 for instruction and guidance for completing this form http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1022/r3/) EGM 11-003, Revision 3 Implementation Duration March 22, 2017 at 1209 Eastern Daylight Time (EDT) Start APPROVED BY OMB: NO. 3150-0104 EXPIRES: 03/31/2020 comments regarding burden estimate to the Information Services Branch (T-2 F43), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

March 28, 2017 at 1230 EDT 2017 - 001

3. LER NUMBER

End - 00 A review of LERs for the past three years identified the following previous similar occurrences.

BSEP will submit a license amendment request to adopt Technical Specification Task Force (TSTF)-542 within 12 months from its approval (i.e., from December 20, 2016).

The safety significance of this event is minimal. As discussed in EGM 11-003, Revision 3, enforcement discretion related to secondary containment operability during Mode 5 OPDRV activities is appropriate because the associated interim actions necessary to receive the discretion ensure an adequate level of safety. To ensure compliance with the interim actions specified in the EGM, BSEP developed plant procedure 2SP-15-101. This procedure was implemented for the OPDRV activities during which secondary containment was not operable.

Safety Assessment

Corrective Actions

Commitments

Previous Similar Events

No regulatory commitments are contained in this report.

CONTINUATION SHEET

(See NUREG-1022, R.3 for instruction and guidance for completing this form http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1022/r3/)

• LER 1-2016-003, dated May 2, 2016, reported implementation of EGM 11-003 during the 2016, Unit 1 refueling outage. The corrective actions for LER 1-2016-003 was to submit a license amendment request to adopt a TSTF traveler associated with generic resolution of this issue within 12 months after the issuance of the Notice of Availability of the TSTF traveler.

• LER 2-2015-001, dated April 24, 2015, reported implementation of EGM 11-003 during the 2015, Unit 2 refueling outage. The corrective actions for LER 2-2015-001 was to submit a license amendment request to adopt a TSTF traveler associated with generic resolution of this issue within 12 months after the issuance of the Notice of Availability of the TSTF traveler.

• LER 1-2014-001, dated May 1, 2014, reported implementation of EGM 11-003 during the 2014, Unit 1 refueling outage. The corrective actions for LER 1-2014-001 was to submit a license amendment request to adopt a TSTF traveler associated with generic resolution of this issue within 12 months after the issuance of the Notice of Availability of the TSTF traveler.

APPROVED BY OMB: NO. 3150-0104 EXPIRES: 03/31/2020 comments regarding burden estimate to the Information Services Branch (T-2 F43), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

2017 - 001

3. LER NUMBER

- 00